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On Tuesday, Oct. 16, the Minnesota Pollution Control Agency (MPCA) held a public information forum regarding Daley Farms of Lewiston, Minn., and the Environmental Assessment Worksheet (EAW) which is part of the operation's current permit application approval process. Daley Farms wants to more than double its dairy herd from 1,728 cows and calves to 4,628 total. This would make it the largest livestock feedlot in southeastern Minnesota, and among the largest in the state.

The Land Stewardship Project, as well as the public, received notice of the Oct. 16 meeting on Sept. 28, leaving little time to prepare. The MPCA announced that the Daleys picked this date for the public information meeting, which, in the end appeared to be more of a public relations/marketing event than an unbiased, public agency-sponsored information and comment session. Many of our Winona County LSP members — farmers and folks with residences nearby — were unable to attend the meeting due to the fact that it was short notice, harvest is in full swing and Oct. 16 was the same day as the Bluff Country Co-op Annual Meeting. LSP members had pushed MPCA Commissioner John Linc Stine to extend the public comment period to Nov. 30 and reschedule the public information meeting. (He extended the public comment period to Nov. 15).

As a result of the short notice, compared to the well-recruited folks in blue shirts provided by Daley Farms, those concerned about that mega-dairy's potential negative impacts appeared to be outnumbered. Despite that, LSP members made up over 60 percent of the comments after the presentation—and their comments were powerful. They made it clear we need an extensive environmental study, called an Environmental Impact Statement (EIS).

Everyone’s testimony was well thought-out, pertinent, heartfelt and personal, AND also factual and relevant to the EAW and the risks at hand. No supporter of this proposed expansion could argue with the integrity, reason, common sense and veracity of those calling for an EIS.

This is about insisting that the MPCA does its job and follows Minnesota law to protect the environment, water quality and quantity, health and quality-of-life for everyone affected. Without a doubt, the scale and implications of this proposed factory farm expansion absolutely require that an in-depth Environmental Impact Statement be completed. It doesn't matter how many pages they add to the assessment worksheet process — an EAW does not do the job of an EIS.

Points to Consider for Comment:

• The project would annually use 92 million gallons of water. The city of Lewiston (pop. 1,564) uses 33.5 million gallons of water per year. What impact will this major use of water have on our aquifer?

• From the EAW: "Daley received DNR's preliminary approval letter to construct the new wells for the Project on October 30, 2017 (Attachement R). The DNR has stated in the preliminary approval letter, that DNR has 'determined that the proposed rate and volume may interfere with other water uses or have negative impacts on nearby lakes, streams or wetlands.' Also, "The DNR's preliminary approval to construct a well is not an approval to use or pump the well."

• The proposal will annually produce 46 million gallons of manure and wastewater in an area where karst geology channels contaminants from surface water deep into the ground.

• Lewiston’s municipal sewage lagoon disappeared into a sinkhole in 1991. What if one of the multi-million gallon lagoons at this project disappears into a sinkhole? The municipal lagoon in Altura failed due to a sinkhole in 1976. The same thing happened in Bellechester in 1992.

• Well testing conducted by the Minnesota Department of Agriculture in 2016 showed that 46.3 percent of the wells tested in Utica Township exceeded the safe drinking water standard for nitrates.

• The proposed manure basin would have a surface area equal to 3.3 football fields – and it’s designed to be 16-feet deep.

• Why is the MPCA doing an EAW on the Daleys' proposed massive expansion when it is not allowed under our Winona County Ordinances? Winona County’s ordinance is clear: no feedlots are allowed over 1,500 animal units. This animal unit cap was passed in 1998. This cap acknowledges the reality that, in karst country, there is a limit to how many animals you can pack into one location when you are storing liquid manure in lagoons.The Daleys' farm was over the 1,500-animal unit cap at the time the ordinance was adopted and so was “grandfathered in.” This means it could continue but could not expand (increase its non-conformity).